S. 45 : Capital gains-Stock option is a capital asset-Gains on exercising option-Stock option given to consultant-Assessable as capital gains -Rule of consistency to be followed when other assesses assessment the claim was accepted as capital gains. [S. 2(14), 2(42A) 2(47), 17(2)(iia)]

S. 43B : Deductions on actual payment-Mercantile system of Accounting-Securities Transaction Tax-Amount not deposited with authorities or returned to person from whom deducted-Disallowance of the amount -Neither perverse nor illegal. [Art. 226]

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Confirmation was filed-Deletion of addition is held to be justified.

S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Books of account not rejected- Transactions involving less than Rs.20,000 – H Forms obtained-Deletion of addition is held to be justified. [S. 37(1)]

S. 40(a)(iib) : Amounts not deductible-Validity of provision-Exclusive Jurisdiction of High Court to consider-Cause of action for challenge to vires of provision arose on issue of show-cause notice-High Court is directed to dispose of writ petition on merits. [Art. 14, 226]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Non-resident-Interest-Usance charges paid on letters of credit issued by Indian Banks for import of raw materials-Income of non-Resident- Liable to deduct tax at source. [2(28A), 5(2), 9(1)(v)(b), 195(1)]

S. 37(1) : Business expenditure-Discount on Debentures-Principle of matching concept not applicable-Amount relating to relevant accounting year alone deductible as revenue expenditure. [S. 145]

S. 37(1) : Business expenditure-Capital or revenue-Contribution towards reconstruction of Bridge to enable transportation of assessee’s products to port-Allowable as revenue expenditure.

S. 37(1) : Business expenditure-Contribution made under specific directions of Government of India to other projects-Contributions to Provident Fund – Held to be allowable as deduction. [S. 36(1)(va), Electricity (Supply) Act, 1948, S. 24]

S. 37(1) : Business expenditure-Capital or revenue-Payment made to an entity under an agreement for additional infrastructure for augmenting continuous supply of electricity-No asset acquired-Held to be allowable as revenue expenditure.